Privacy Policy

Introduction

StrataNova Capital LLC ("StrataNova," "we," "us," or "our") operates a thematic investment analytics platform (the "Platform") and the website located at stratanova.io (the "Site"). This Privacy Policy explains how we collect, use, disclose, and protect information about you when you visit our Site, use our Platform, or otherwise interact with us, including when you receive marketing communications from us.

By accessing the Site or using our Platform, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use our Site or Platform.

Information We Collect

Information You Provide Directly

• Contact information such as your name, email address, firm name, and job title when you fill out a form, request a demo, or contact us.
• Account credentials when you register for Platform access. Passwords are managed by Clerk, a third-party identity provider, and are never stored by StrataNova in plaintext or in any accessible form.
• Payment information including billing details. Payment card data is processed directly by Stripe, Inc. and is never stored on StrataNova's infrastructure.
• Custom portfolio data, including ticker selections and model portfolio compositions entered for analytical purposes ("Client Portfolios"). Client Portfolios do not include live brokerage positions, share counts, or dollar values unless voluntarily entered by Client.
• Communications you send us, including emails and support requests.

Information Collected Automatically

• Usage data including pages visited, features accessed, session duration, dwell time, and actions taken on the Site and Platform.
• Device and browser information including IP address, browser type, operating system, and referring URLs.
• Authentication and session data managed by Clerk, which may collect IP addresses, device information, and login timestamps.
• Cookies and similar tracking technologies as described in Section 6 below.
• Email engagement data, including open rates and link clicks, collected via tracking pixels in our marketing and outreach emails. You may opt out at any time by contacting us at jack@stratanova.io.

Information from Third Parties

• Publicly available regulatory filing data sourced from the SEC's EDGAR database, including Form 13F, Form ADV, and NPORT filings, used to populate Platform analytics.
• Market and pricing data sourced from licensed third-party data providers including Databento.
• SEC filing data accessed via sec-api.io, a third-party API provider for EDGAR data retrieval.
• Email address verification data from third-party services used to validate contact information prior to outreach. This data is used solely for sales operations and is not shared with or linked to client platform data.

How We Use Your Information

Providing the Platform

To operate, maintain, and improve the Platform and its features, including processing Client Portfolios and delivering analytics.

Account Management

To create and manage your account, deliver credentials, and provide customer support.

Payment Processing

To facilitate billing and payment collection through our third-party payment processor, Stripe. StrataNova does not directly process or store payment card information.

Marketing and Outreach

To send outreach emails to prospective clients and marketing communications to existing clients about our products and services. Prospective client contact information used for outreach is sourced independently from publicly available sources, including SEC regulatory filings, and is never derived from data submitted to the Platform by any subscriber. Recipients of marketing emails may opt out at any time by clicking the unsubscribe link in any email or by contacting us directly. We do not require prior opt-in consent for business-to-business outreach to professional contacts, consistent with applicable law.

Analytics and Improvement

To understand how users interact with our Site and Platform, diagnose technical issues, and develop new features. We may use aggregated, anonymized data derived from usage data for these purposes, provided such data cannot reasonably identify you or your firm.

Legal and Compliance

To comply with applicable laws and regulations, enforce our agreements, and protect the rights, property, and safety of StrataNova and others.

How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

Service Providers and Subprocessors

We share information with vendors who assist us in operating the Platform and Site. Our current subprocessors include:

These providers are contractually required to use your information only as directed by us and to maintain appropriate security measures.

Aggregated Data

We may share aggregated, anonymized data that cannot reasonably identify any individual or firm with third parties for research, marketing, or analytics purposes.

Business Transfers

If StrataNova is involved in a merger, acquisition, or sale of substantially all of its assets, your information may be transferred as part of that transaction. We will notify you via email or prominent notice on our Site prior to such transfer.

Legal Requirements

We may disclose your information if required to do so by law, regulation, or court order, or if we believe in good faith that such disclosure is necessary to protect the rights or safety of StrataNova, our users, or others.

With Your Consent

We may share your information for any other purpose with your prior written consent.

Data Security

We implement and maintain commercially reasonable technical and organizational security measures designed to protect your information against unauthorized access, disclosure, alteration, or destruction. Specifically:

• All data stored on our infrastructure, including Client Portfolios, is encrypted at rest and in transit using industry-standard encryption protocols.
• User authentication and credential management is handled by Clerk, a SOC 2 Type II certified identity provider. Passwords are never stored by StrataNova in plaintext or in any accessible form.
• Payment processing is handled by Stripe, Inc., which is PCI DSS Level 1 certified. StrataNova does not store, transmit, or have access to Client payment card data.
• Access to Client data is restricted to authorized personnel and service accounts with least-privilege access controls.
• Network access to our data infrastructure is restricted to authorized IP ranges only.

In the event of a confirmed security breach resulting in unauthorized access to your personal information, we will notify affected users without undue delay and no later than seventy-two (72) hours of becoming aware of such breach, to the extent required by applicable law.

No method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our Site to enhance your experience and collect usage information. Specifically, we use:

• Session cookies to maintain your login state and Platform session.
• Analytics cookies to understand how visitors interact with our Site, including pages visited and time spent.
• Email tracking pixels embedded in marketing and outreach emails to measure open rates and link clicks. You may opt out by contacting us at jack@stratanova.io.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Note that some features of our Site or Platform may not function properly if cookies are disabled.

Our Site does not currently respond to "Do Not Track" signals. If you wish to limit tracking, you may disable cookies in your browser settings.

Data Retention

• Account and contact information is retained for the duration of your subscription and for a reasonable period thereafter to comply with legal obligations and resolve disputes.
• Client Portfolios, including ticker selections and model portfolio compositions, are retained for the duration of your subscription. Upon termination and written request, we will delete Client Portfolios within thirty (30) days.
• Usage data and email engagement data are retained for as long as necessary for operational and analytics purposes.
• Publicly sourced regulatory data retrieved from the SEC's EDGAR database, including Form 13F, Form ADV, and NPORT filings, is retained indefinitely as it constitutes public information and is not subject to deletion obligations.
• Prospect contact information used for outreach is retained until you opt out or request deletion.

Your Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including:

• The right to access the personal information we hold about you.
• The right to correct inaccurate or incomplete information.
• The right to request deletion of your personal information, subject to certain exceptions.
• The right to opt out of marketing communications at any time by clicking the unsubscribe link in any email we send or by contacting us at jack@stratanova.io.

California Residents (CCPA)

If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (CCPA):

• The right to know what personal information we collect, use, disclose, and sell about you.
• The right to request deletion of your personal information, subject to certain exceptions.
• The right to opt out of the sale or sharing of your personal information. StrataNova does not sell or share personal information as defined under the CCPA.
• The right to non-discrimination for exercising your CCPA rights.
• The right to limit the use and disclosure of sensitive personal information. StrataNova does not use sensitive personal information for purposes beyond those permitted by the CCPA.

To exercise any of your CCPA rights, please contact us at jack@stratanova.io. We will respond to verifiable consumer requests within forty-five (45) days.

Third-Party Links

Our Site and Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties, and this Privacy Policy does not apply to their websites or services. We encourage you to review the privacy policies of any third-party sites you visit.

Children's Privacy

Our Site and Platform are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

• StrataNova Capital LLC
• Website: stratanova.io
• Email: jack@stratanova.io
• Location: Boston, Massachusetts

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date and version number at the top of this page. For material changes, we will provide notice via email or a prominent notice on our Site at least thirty (30) days prior to the change taking effect. Your continued use of the Site or Platform following notice of any changes constitutes your acceptance of the updated Privacy Policy.

Governing Law

This Privacy Policy is governed by the laws of the State of Delaware, without regard to its conflict of law provisions, consistent with StrataNova's Subscription Agreement.